Editor's Note: This article was originally published by RealClear Education and is cross-published here with permission.
The SAFE Research Act aimed to protect American research from Chinese exploitation. But it left open a critical vulnerability: a class of U.S. educational institutions that fall outside traditional research oversight yet operate squarely in strategically sensitive fields.
The U.S. has long been vulnerable to efforts by the Chinese Communist Party to steal important research from American universities, to influence American faculty, and win the approval of American students. Last year, House lawmakers moved to tighten research-security rules by advancing the Securing American Funding and Expertise from Adversarial Research Exploitation Act (the SAFE Research Act) through their version of the National Defense Authorization Act (NDAA). That effort ultimately stalled, but it revealed something more important: Washington’s focus remains narrowly fixed on elite research universities, leaving an entire tier of technically sensitive institutions—vocational and applied-degree programs included—largely outside the national security conversation.
Congress debates the (NDAA) largely as a question of ships, missiles, and troop pay. Yet in 2025, universities entered the bill’s strategic perimeter. House China Committee Chairman John Moolenaar pushed to incorporate the SAFE Research Act into the NDAA, tying federal research funding to disclosures of affiliations with hostile foreign entities. By advancing the SAFE Research Act through the NDAA, Congress signaled that strategic competition with China extends not only to defense contractors and semiconductor fabs but also to American university campuses.
Congressional investigations preceding the SAFE Research Act framed academic cooperation not as a series of isolated lapses but as a systemic architecture of engagement. Reports from the House Select Committee on the Chinese Communist Party and the Committee on Education and the Workforce, for example, the CCP on the Quad and the Joint Institutes, Divided Loyalties, depict a governance model resembling a hub-and-spoke network: a CCP-controlled higher-education network that uses foreign universities as access points for talent, expertise, and research aligned with Beijing’s priorities. Joint institutes and degree-granting partnerships, in particular, served as durable conduits into China’s state-directed research ecosystem. What congressional investigators reconstructed through hearings and reports reflects a system that already exists in formalized form within China’s own governance framework.
China treats educational cooperation not as cultural exchange but as an instrument of state power serving national development goals. China’s Ministry of Education makes this approach visible through a centralized public registry of Sino-foreign cooperative education institutions and programs, which classifies foreign partnerships by legal status, degree-granting authority, and institutional permanence rather than by discipline, region, or scholarly aim. The registry reveals an administrative logic in which the foreign universities are not merely collaborators but licensed participants embedded at varying depths within China’s higher-education system.
The catalog lists more than a hundred U.S. universities and educational institutions engaged in joint institutes or degree programs with Chinese counterparts, including those overseen by the defense-industrial universities known as the “Seven Sons of National Defense.” This group, historically tasked with supporting China’s defense sector and now central to its military–civil fusion strategy under the Ministry of Industry and Information Technology, occupies a privileged position in Beijing’s research and talent-development ecosystem.
By contrast, the United States and other Western societies treated academic cooperation with China as largely innocent cultural and educational exchange. Policymakers focused overwhelmingly on elite research universities, assuming that national-security risk scaled primarily with grant size, laboratory sophistication, and classified research. That assumption obscured a different class of institutions whose strategic relevance does not depend on prestige or basic research intensity.
One example of this overlooked tier is Embry-Riddle Aeronautical University (ERAU), headquartered in Daytona Beach, Florida, with a major residential campus in Prescott, Arizona. It is a long-established institution known for training students in aviation, aerospace, and related technical fields. On its face, ERAU does not resemble the elite research universities that dominate congressional debates over China and academic security. ERAU matters because it represents a category of institutions that sit below the threshold of most research-security scrutiny but above the threshold of national security relevance.
Beginning in 2011, ERAU established joint degree programs with Chinese institutions, including Nanjing University of Aeronautics and Astronautics (NUAA), the University of Shanghai for Science and Technology (USST), and the Civil Aviation University of China (CAUC). These joint programs focused on aerospace, aviation, and engineering disciplines that had long been classified as dual-use. Notably, NUAA—one of the “Seven Sons of National Defense”—was placed on the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) Entity Listin 2020, which subjects foreign institutions to export-control licensing requirements for activities deemed contrary to U.S. national security or foreign-policy interests. In addition, USST was placed on the federal Unverified List in 2022, indicating that U.S. authorities could not confirm the reliability of its end-use or research practices. Although ERAU no longer publicly documents these programs, Chinese institutional materials document these partnerships well beyond their initial launch, including renewed announcements in 2017 and application guidance still posted in 2019.
The legacy of these programs demonstrates that academic partnerships create lasting professional networks that persist even after institutions formally withdraw. Alumni of the former joint tracks now work across the United States and allied economies, including at major American firms such as American Airlinesand Google. ERAU is not a standalone case. Its former partner, USST, publicly listedjoint-degree and exchange programs with several other U.S. universities—including Missouri, Massachusetts, and North Dakota—suggesting a replicable cooperation model rather than isolated cases. Structured academic cooperation generates durable human and professional networks that outlast the lifespan of institutional agreements, particularly in sensitive fields where skills and tacit knowledge transfer over time. What drew scrutiny was not student performance or intent, but the difficulty of observing, measuring, and governing how these networks continue to shape talent once institutional ties fade from public view.
Informal academic collaboration, through coauthored publications, research groups, graduate advising, conference partnerships, and technical working teams, poses one of the most difficult challenges in research security. These relationships generally fall under “academic freedom” and require no memoranda of understanding or institutional agreements, yet remain central to the circulation of scientific knowledge, particularly in engineering and applied technical fields where data, methods, and unpublished results may carry strategic value.
Open-source publication databases, for instance, show ERAU researchers coauthoring with counterparts at Northwestern Polytechnical University (NWPU) in computer science and applied mathematics in a 2025 IEEE Access article on network reconstruction—an area central to data engineering and algorithm design. NWPU (another prominent institution on the “Seven Sons” list) is a long-standing BIS Entity–listed university associated with China’s defense-industrial system, demonstrating how informal scholarly ties can persist even in the absence of formal institutional partnerships. This helps explain why the SAFE Research Act defined “affiliation” broadly when conditioning eligibility for federal research funding. Although ERAU is a private institution, it participates in publicly supported research and workforce development activities, including federally funded projects announced in partnership with the National Aeronautics and Space Administration (NASA) and indirectly state-supported aerospace and aviation initiatives in Florida and Arizona. In that context, even informal academic collaborations fall within the category of relationships Congress sought to make transparent under the SAFE Research Act.
While the SAFE Research Act focused on federally funded university research, it left largely unexamined preparatory and secondary-level partnerships that shape long-term talent pipelines without triggering disclosure requirements. For example, since at least 2021, the Western International School of Shanghai (WISS) has incorporated ERAU coursework into a dual-enrollment aeronautics pathway, embedding institutional affiliation into early-stage technical education in aeronautics, engineering, and aviation business. Such arrangements fall outside existing research-security regimes, yet they integrate faculty interaction and branded academic credentials into strategically sensitive fields well before students enter U.S. higher education. These programs highlight an oversight gap: consequential academic cooperation can persist and scale in forms not contemplated by policies designed for formal research agreements.
Strategic competition no longer begins solely at shipyards or semiconductor fabrication plants—it begins in classrooms, laboratories, and collaborative research networks where expertise circulates across borders. The SAFE Research Act matters because it recognizes that the governance of knowledge itself has become a national security concern. ERAU’s experience illustrates how decentralized U.S. academic practices intersect with China’s state-managed model of educational cooperation across formal, informal, or even preparatory levels. Taken together, this suggests that aligning research-security policy with the realities of global academic competition will require frameworks that account for enduring networks, informal collaboration, and early-stage talent formation, not only formally disclosed research partnerships.
Photo by Myvector on Adobe Stock
